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FEHBP Final Rule on Provider Sanctions

Client Alert | 1 min read | 03.08.04

The Office of Personnel Management ("OPM") has issued a final financial sanctions rule for health care providers participating in the Federal Employees Health Benefits Program ("FEHBP"). Two categories of financial sanctions are established by the March 3 rule: assessments, which are intended to recognize losses, costs, and damages incurred as the result of a provider's wrongful conduct, and civil monetary penalties, which are lump-sum amounts that, while computed by reference to improper claims, are intended principally to deter future violations. The bases for financial sanctions are (1) fraudulent or improper claims; (2) false or misleading statements in or about claims; and (3) failure to provide claims-related information that is required by law to be disclosed. Sanctions may be imposed only for violations that directly involve FEHBP enrollees, carriers, or funds. The final rule sets forth the procedures for imposing, determining the amount, and collecting financial sanctions, as well as providers' right to contest and appeal the imposition of financial sanctions. The March 3 final rule also clarifies the circumstances under which payments may be made from FEHBP funds to suspended providers. This rule, along with the rule governing suspension and debarment of FEHBP providers, implements the administrative sanctions enacted by the Federal Employees Health Care Protection Act of 1998 (Pub. L. 105-266).

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Client Alert | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....